ESMA have released the final version of their report to the EU commission.
The document (a 90 pages thriller) can be found here.
The EU commission now has three months to respond.
The most important aspects and/or changes for NFC-s in a nutshell (please note that these are - for the time being - just recommendations by ESMA):
1. No exemption of intra-group trades, dual-sided reporting for all counterparties / trades still necessary (both aspects have not even been mentioned in the report).
2. Backloading period extended to five years (instead of three years)- some market participants hoped that the backloading obligation will be abandoned, which is obviously not the case.
3. All counterparties will have to report a so-called 'corporate sector' - this will be supported by EMIRate
4. Last, but not least a - as we think - really funny aspect - for options, in the future the strike price has to be reported as notional. We had to look twice, we rubbed our eyes, but it still was there, black on white. Interesting, Watson!
As mentioned before, these are just proposals. We don't accept any bets, but firmly believe that this will come as proposed by ESMA.